thabametsi-nersa-objections-27-c562776ef1b90122.pdf

This document is a supplementary affidavit submitted by Earthlife Africa NPC to the National Energy Regulator of South Africa (NERSA). It presents formal objections to the license application of Thabametsi Power Company (Pty) Limited for a proposed 1200MW coal-fired power plant in Lephalale, Limpopo. Earthlife argues that the project is unnecessary, financially inefficient, and poses severe risks to water security, air quality, and climate goals.

• Earthlife Africa contends that the Thabametsi power station is not required to meet South Africa's energy demand, citing research from the Council for Scientific and Industrial Research (CSIR) and Meridian Economics. The document asserts that electricity from Thabametsi would be at least 40% more expensive than recent renewable energy projects, with coal power costing R1.03 per KWh compared to 62c per KWh for solar PV and wind.
• The proposed power station is located in the Mokolo Catchment and the Waterberg-Bojanala Priority Area, both of which are under significant environmental stress. The document states that the project would exacerbate air pollution in a region already designated as a priority area due to non-compliance with National Ambient Air Quality Standards (NAAQS).
• Thabametsi's own climate change impact assessment (CCIA) identifies the project's greenhouse gas (GHG) emissions as 'Very Large', the highest possible rating, resulting in an overall significance rating of 'High (Negative)'. The document argues that these emissions would contradict South Africa's commitments under the Paris Agreement and its Nationally Determined Contribution (NDC).
• There are severe concerns regarding water security for the plant. Thabametsi relies on the Mokolo Dam, where demand is expected to exceed supply by 2019. Its long-term viability depends on the Mokolo-Crocodile Water Augmentation Project Phase 2 (MCWAP2), which is described as long delayed and facing technical, financial, and environmental risks.
• The document highlights risks associated with the proposed toxic coal ash dump, which is reportedly sited over several fault lines. This placement is claimed to threaten the underlying aquifer and surrounding ecosystems if toxic ash leaches out.
• Air dispersion modelling by Dr. Ranajit Sahu and Dr. Andy Gray indicates that the combined emissions from Thabametsi, the Thabametsi mine, and the existing Matimba and Medupi power plants would significantly degrade air quality and likely cause exceedances of the NAAQS for sulphur dioxide (SO2), oxides of nitrogen (NOx), and particulate matter (PM).
• Earthlife Africa challenges the Minister of Environmental Affairs' decision to uphold Thabametsi's environmental authorisation. The objection is based on the claim that the Minister improperly relied on the outdated IRP 2010 as justification, failed to consider the social cost of GHG emissions, and acted procedurally unfairly by not allowing public comment on the EOH Peer Review.
• The document argues that the project is a potential 'stranded asset' due to the combined effects of climate change—which is expected to reduce water flows in the Mokolo and Crocodile West catchments—and South Africa's legal obligations to reduce emissions toward 'near zero' by the second half of the century.
• Earthlife raises procedural objections regarding NERSA's public hearing process, specifically that the hearings were held in Pretoria rather than in the local areas where the power stations would be based, effectively excluding community members who cannot travel.

APA

Centre for Environmental Rights (n.d.). thabametsi-nersa-objections-27-c562776ef1b90122.pdf. https://cer.org.za/wp-content/uploads/2018/05/Thabametsi-NERSA-objections-27.pdf?x21779

Chicago

Centre for Environmental Rights. thabametsi-nersa-objections-27-c562776ef1b90122.pdf. n.d. https://cer.org.za/wp-content/uploads/2018/05/Thabametsi-NERSA-objections-27.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=thabametsi-nersa-objections-27-c562776ef1b90122.pdf |url=https://cer.org.za/wp-content/uploads/2018/05/Thabametsi-NERSA-objections-27.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrightsndthabametsinersaobjections27c562776ef1b90122pdf, author = {{Centre for Environmental Rights}}, title = {{thabametsi-nersa-objections-27-c562776ef1b90122.pdf}}, publisher = {Centre for Environmental Rights}, url = {https://cer.org.za/wp-content/uploads/2018/05/Thabametsi-NERSA-objections-27.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }